ARTICLE · 13 SEPTEMBER 2023

Modernization Of Cyprus Transfer Pricing Legislation

Eurofast

Explore more from Eurofast

On the 6th of July 2023, a new circular was issued by the Tax department, in addition to the one voted in 2022, that takes into consideration the related transactions which are lower of the threshold

CyprusTax

Avraam Apostolou

Author LinkedIn connections

On the 6^th of July 2023, a new circular was issued by the Tax department, in addition to the one voted in 2022, that takes into consideration the related transactions which are lower of the threshold of €750,000 in aggregate per type of transaction in a tax year. It is applied retrospectively from the 1^st of January 2022 and a simplified documentation file will need to be provided to the authorities upon request in 60 days' time.

The contents of the simplified documentation file should consist of the below:

a summarised description of the Company's functional analysis based on its functions, assets, and risks.
the Company's characteristics based on its functional analysis.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

Cyprus Extends The Transitional Home VAT Route To 31 December 2026 For Qualifying Delayed Projects

Philippou Law Firm

70% Of Your 2024 Profits Become A 17% Dividend On 31 December 2026

CYAUSE Audit Services Ltd

Cyprus Removes The Foreign Tax Residence Restriction From Its 60 Day Rule

Philippou Law Firm

Cyprus Cuts Defence Contribution On Dividends And Abolishes It On Rents

Philippou Law Firm

Cyprus Companies Approach Their First Year End Under The 15 Percent Corporate Tax Rate

Philippou Law Firm

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Transfer Pricing
- Tax Authorities

Related Comparative Guides

Comparative Guide

Tax

Comparative Guide

Tax Disputes

See more popular content from

Tax

Tax Webcast September 2019 (Video)

Welcome to our 5 minute tax update broadcasted monthly. The aim of our tax webcasts is to provide a brief summary of local and international tax events impacting Cyprus.

Deloitte Cyprus

Cyprus Tax Department Opens 2023 Income Tax Return (IR1) Submission On TaxisNet

The Cyprus Tax Department has announced that the 2023 Income Tax return (IR1) for Individuals can now be submitted via the TaxisNet system.

Cyprus Corporate Tax 2026: Frequently Asked Questions

Cyprus corporate tax changed materially on 1 January 2026. The headline change is the corporate tax rate, which rose from 12.5% to 15%. But the reform package went further, touching loss carry-forward..

Nikita & Partners Limited

Cyprus Corporate Tax Is Now 15%: Who Pays 8 Points Less, And Why Non-Doms Pay More

Cyprus has raised its corporate income tax rate from 12.5% to 15%, but the total tax burden on distributed profits has actually fallen by more than eight percentage points for Cyprus-domiciled shareholders due to a dramatic cut in the Special Contribution for Defence on dividends. However, non-domiciled residents and foreign shareholders now face higher effective rates, fundamentally reshaping the island's tax competitiveness for different investor categories.

CYAUSE Audit Services Ltd

You Can Now Be Cyprus Tax Resident In 60 Days Even If Another Country Still Claims You

Cyprus removed a key barrier to its 60-day tax residency rule in January 2026, allowing applicants to qualify even if another country still claims them as tax resident. The change shifts the resolution of competing residency claims from domestic statute to double tax treaty tie-breaker provisions, fundamentally altering how internationally mobile business owners and executives can establish Cyprus tax residency.

CYAUSE Audit Services Ltd

Cyprus Tax Residency And Non-Domicile Status In 2026: Legal And Practical Considerations For International Business Owners

Cyprus has increasingly positioned itself as a jurisdiction of interest for entrepreneurs, international business owners, remote professionals and high-net-worth individuals seeking an EU base with a modern...

A. Danos & Associates LLC

Cyprus Tax Reform 2026: Key Changes For Individuals And Businesses

Cyprus approved a comprehensive tax reform package on 22 December 2025, marking the first major overhaul of the tax system in more than twenty years.

Michael Chambers & Co LLC

Cyprus Personal Taxation: What Foreign Investors And Employees Need To Know Following The January 1, 2026 Tax Reform

The Cypriot tax landscape has undergone a significant recalibration following the entry into force of a broad package of fiscal reforms, effective as from the 1st of January, 2026.

Elias Neocleous & Co LLC

Cyprus Capital Gains Tax On Shares: The Investor's Guide

A Cyprus resident company holding a portfolio of listed securities, funds, or bonds can generate capital gains and dividend income entirely free of corporation tax.

Nikita & Partners Limited

Cyprus Tax Residency: The Definitive Guide To The 60-Day Rule, Non-Dom Status, And Tax-Free Dividends (2026)

Cyprus tax residency has become the subject of intense interest among internationally mobile business owners and entrepreneurs. The reason is straightforward: Cyprus offers a legal, transparent, and well-tested framework...

Nikita & Partners Limited